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cattle breeding activity where no cattle inventory records kept).
Similarly, with respect to the financial ledgers for Maple
Row maintained by Mrs. Burrus, we find that these records, though
not flawless, represented a reasonably accurate attempt to record
the activity’s financial results. Moreover, petitioners
maintained separate bank accounts for the purpose of conducting
Maple Row’s affairs. When cash was transferred from personal or
other accounts to Maple Row’s accounts, the transfer was recorded
in the ledgers. Cf. id. (no separate bank account for cattle
activity).
Respondent’s expert postulated several criteria to which he
believed a profit-oriented purebred cattle breeding operation
would adhere, and found Maple Row’s practices at variance with
those criteria. To the extent the expert’s testimony was
intended to show that petitioners conducted their cattle breeding
activity in a manner not substantially similar to like activities
conducted for profit, we are unpersuaded. Respondent’s expert
cited the need for genetically superior stock, but then opined
merely that he was unable to determine from the records provided
him whether petitioners had such stock. In this regard, it is
worth noting that the expert cited in his report petitioners’
documentation to the effect that Maple Row had received the
designation “1998 Top Recorders in Tennessee” for having
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